U.S. traders are buying 'digital residency' in Palau to skirt restrictions on the amount of cryptocurrency they can withdraw and the exchanges they can use. Major exchanges have already banned the ID, fearing abuse.
It can technically be used to extend your stay in Palau long enough to establish tax residency since it would allow you to stay in Palau for longer than 183 days a year. Not unusual for people sitting on big crypto stashes to move abroad or buy citizenships in order to cash out their crypto without capital gains tax (or at least that’s how it goes - I imagine the IRS doesn’t go down that easily).
If you spent a full 210 days (30 days from a visa on arrival followed by 2 consecutive 90-day extensions) each year in Palau, but spent the remainder of every year in the USA, you would be physically present in the United States (U.S.) on at least “183 days during the 3-year period that includes the current year and the 2 years immediately before that”. Specifically, the “count” would be 232.5 (instead of 465 since days in earlier years are counted as 1/3 or 1/6), which is at least 183.
It seems the easiest way to avoid being considered a United States resident for tax purposes from meeting the substantial presence test is to not be physically present in the United States (U.S.) on at least 31 days during the current year. If you wanted to do that, there are many places where most United States citizens are already allowed to stay for “365 days” or “1 year” or “Unlimited”, notably including Palau, as well as Marshall Islands and Albania and other countries: https://en.wikipedia.org/wiki/Visa_requirements_for_United_States_citizens
That’s for actual residency. This seems to be able to exist in the country digitally. Other countries, like Estonia, have the same thing.
It can technically be used to extend your stay in Palau long enough to establish tax residency since it would allow you to stay in Palau for longer than 183 days a year. Not unusual for people sitting on big crypto stashes to move abroad or buy citizenships in order to cash out their crypto without capital gains tax (or at least that’s how it goes - I imagine the IRS doesn’t go down that easily).
The “substantial presence test” is more complicated than you might have thought: https://www.irs.gov/individuals/international-taxpayers/substantial-presence-test
If you spent a full 210 days (30 days from a visa on arrival followed by 2 consecutive 90-day extensions) each year in Palau, but spent the remainder of every year in the USA, you would be physically present in the United States (U.S.) on at least “183 days during the 3-year period that includes the current year and the 2 years immediately before that”. Specifically, the “count” would be 232.5 (instead of 465 since days in earlier years are counted as 1/3 or 1/6), which is at least 183.
It seems the easiest way to avoid being considered a United States resident for tax purposes from meeting the substantial presence test is to not be physically present in the United States (U.S.) on at least 31 days during the current year. If you wanted to do that, there are many places where most United States citizens are already allowed to stay for “365 days” or “1 year” or “Unlimited”, notably including Palau, as well as Marshall Islands and Albania and other countries: https://en.wikipedia.org/wiki/Visa_requirements_for_United_States_citizens
Ah, thank you.
Used to be the DOJ had an expansive view of USA sovereignty. Guess we will see.